" ... Contains practice guidance for representing a client during the lifecycle of a civil or criminal tax examination, appeal and litigation. The [book] presents an overall discussion of IRS procedures, and practical and strategic considerations."--Publisher insert, October 2017.

To access the 2015-16 Supplement to this text, click here. To access the 2016 Letter Update to the Supplement, click here. This casebook teaches the mechanics of tax procedure, while stimulating students to think about the broader issues that underlie its structural framework. This edition of Tax Controversies: Practice and Procedure begins with an overview of civil tax procedure and an in-depth discussion of the federal tax gap and the many approaches to closing it. Several of the next chapters focus on stages in the chronology of a typical tax controversy, from examination through eventual litigation. In addition, two chapters focus on tax research and representing tax clients and a new chapter addresses ethics issues in tax cases. An underlying theme - the extent to which the current procedural rules encourage or discourage voluntary compliance with the federal tax system--runs throughout the book. Suitable for J.D. or LL.M. students, or for use in a tax clinic. This edition contains new chapters on summons enforcement, the U.S. Tax Court, the collection due process procedures, "innocent spouse" relief, and ethics issues. Each casebook chapter includes theory questions and a set of fact-based problems to encourage strategic thinking. Several chapters include optional drafting problems. Teacher's Manual provides detailed answers to the problem sets, suggests approaches to the material, and highlights topics more suitable for an advanced course. Separate Documents Volume, Tax Controversies: Statutes, Regulations, and Other Materials, is also available.

View or download the free 2015 Online Supplement for this product. Civil Tax Procedure embodies the dual goals established for the LexisNexis Graduate Tax Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. To this end, the text relies very little on the often-times laborious analysis of cases and other sources that are secondary to the Code and the regulations. Instead, each chapter provides an overview of the substantive content, with emphasis on important issues that are not apparent from the language of the Code and regulations. The problems are designed to require the students to study the assigned sections of the Code and regulations and, for the most part, do not lend themselves to resolution by simply reading the book. Areas that are often difficult for students (and practitioners alike), such as the partnership audit provisions, the innocent spouse rules, judicial and statutory mitigation of the statute of limitations, and transferee and fiduciary liability are addressed in the text and through 'real world' problems. The Teacher's Manual includes not only comprehensive analyses of all problems presented in the coursebook, but also lecture notes on some of the most difficult topics developed by the authors whose combined practice and teaching careers span almost 100 years.

This book serves as an introductory or supplemental teaching tool on the federal tax system. It can be used for a variety of course or seminar topics, including civil tax practice, criminal tax practice and procedure, and tax ethics.